Linpac Plastics, Inc. - Executive Summary

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    This Executive Summary comprises the Rule 40 CFR 68.155 of 
the Clean Air Act as it applies to Linpac Plastics.  The Tasks, 
1-4 indicate Environmental Engineering Consultants, Inc.'s 
evaluation of Linpac Plastics' compliance with the stated Rule. 
40 CFR Part 68.155(a): 
Accidental release prevention and emergency response policies; 
    Linpac's Process Safety Management (PSM) Policy requires 
daily inspections by maintenance mechanics and the Plant 
Engineer.  Butane gas detectors are located in the Butane 
Storage Tank Area and in the Butane Pump Room.  These detectors 
are connected to a butane detection warning panel with lights and 
a warning horn, it is also integrated into the fire alarm system.  
Butane pumps and motors are regularly rotated with their backups 
to verify proper working order and to allow for scheduled 
maintenance.  The Accidental Release Prevention Plan (ARP) is to 
call 911 for emergency response, sound the evacuation ala 
rm and 
evacuate the building.  If possible, the butane emergency 
shut-off will be activated and the power turned off to the butane 
motors.  Operators will turn their equipment off as they 
evacuate.  Maintenance supervisors and lead operators will 
provide first aid until paramedics arrive. 
    TASK 1 was to perform a Process Safety Management and 
Accidental Release Plan (PSM/ARM) Compliance Audit.  This 
compliance audit indicated good overall compliance and 
excellent results, with no accidents related to the Butane 
System. We recommend that all procedures be updated with the same 
format as the "Hazard Communication Plan", and that a 
"Date of Next Revision Due_____" statement be added to clarify 
the age of the procedure. 
40 CFR Part 68.155(b):  
Stationary source and regulated substances handled; 
    Linpac Plastics, Inc. is a manufacturer of polystyrene 
plastic.  Linpac sells the polystyrene to clients and also uses 
it to manufacture various plastic containers, such 
as egg 
cartons and "carry out" food containers.  Butane is used as a 
blowing agent in the manufacturing process.  Butane is stored on 
site in an 18,000 gallon tank under pressure.  Butane is the only 
"regulated substance" handled by Linpac Plastics. 
40 CFR Part 68.155(c): 
Worst case release scenario(s) and the alternative release 
    TASK 2 was to perform a review of the hazard assessment 
elements.  An off-site consequence analysis was required to 
evaluate specific potential release scenarios, with a worst-case 
scenario and an alternative case for computer modeling. 
*    The worst case release scenario indicated a vapor cloud 
    explosion would have an effect to a distance of 0.2 
    miles (1000 feet).  Our research indicates that three (3) 
I.   EXECUTIVE SUMMARY continued: 
    vacant buildings, four (4) active businesses, and two 
    (2) Sebring Airport Authority maintenance buildings, and the 
    water plant could potentially be affected i 
n this scenario  
    (Figure 1, Map of 1,000 feet radius). 
*    The Alternative Release Scenario indicated that a vapor 
    cloud fire would have an effect to 0.1 miles (500 feet).  
    The vapor cloud fire scenario could affect one (1) 
    active business, three (3) vacant buildings and the 
    Sebring Airport Authority water plant (Figure 2,  Map of 500 
    feet radius).  The residential population and the 
    environmental receptors are not affected by either 
Linpac's Administrative Controls and Mitigation   Measures 
include the following: 
*    The butane gas detection sensors, with monitoring 
    system and associated alarm. 
*    A locked gate and the chain link fence enclosing the 
    tank and the unloading station. 
*    Back up pumps and motors. 
*    Explosion-proof equipment. 
*    Gravel has been placed around the tank and the 
    unloading station to dissipate a spill. 
*    Only trained mechanics are allowed to perform 
ance on the butane system. 
*    Safety procedures are reviewed during Safety Meetings. 
40 CFR Part 68.155(d): 
General accidental release prevention program and 
chemical-specific prevention steps;  
The general Accidental Release Prevention Program and 
Chemical-Specific Prevention Steps are as follows: 
*    Only trained maintenance mechanics are allowed to perform 
    maintenance on the butane system. 
*    All work is reviewed by a supervisor and the Plant Engineer  
    before it is performed to ensure compliance with safety  
    rules and to prevent an accidental release. 
*    In general, all maintenance work related to the butane 
    system is performed using a two-person team to ensure safety 
    compliance and to prevent an accidental release. 
*    A butane trained employee is always present during the 
    unloading process to ensure safety compliance and to prevent 
    an accidental release. 
*    The program complies with safety precautions, monitoring, 
   record keeping, reporting, operator training, vapor     
    recovery, secondary containment, work practices, standard 
    operating procedures modifications as needed, the generation 
    of a "Hot Work Permit", and the OSHA PSM Rule. 
I.   EXECUTIVE SUMMARY continued:      
    TASK 3 was to develop a Detailed Accidental Release 
Prevention Program.  Our review indicated that four areas needed 
to be addressed to be in full compliance with the regulations. 
    1.   Initiate safety compliance audits. 
    2.   Implement an incident investigation procedure, and 
    3.   Implement an Employee Participation Plan.  
    4.   Perform a design review of compliance with the National 
         Fire Protection Association Codes relevant to the  
         butane system. 
40 CFR Part 68.155(e) 
Five-year accident history; 
    Linpac safety records indicate that there have been no 
accidents related to the butane system during the last five (5) 
40 CFR P 
art 68.155(f) 
Emergency response program; 
    TASK 4 was to develop an Emergency Response Program.  We 
have chosen to use the 911 emergency phone system as our 
Emergency Response Program (ERP).  The Sebring Regional Airport 
Volunteer Fire Department is less than one mile away and has been 
notified of the existence of the butane tank, in compliance with 
the State Emergency Response Program.  The fire department has 
agreements with fire departments in three surrounding cities 
(DeSoto City, Lorita and the City of Sebring) to provide 
assistance when needed.  Linpac's ERP identifies only the actions 
to take until the Fire/Rescue Personnel arrive.  
40 CFR Part 68.155(g) 
Planned changes to improve safety 
    To improve safety at the facility, the following procedures 
will be implemented: 
    *    A portable butane detection monitor will be purchased 
         and utilized. 
    *    Evacuation drills will be practiced. 
    *    Safety Compliance Audits will be initiat 
    *    An Incident Investigation Procedure will be instituted. 
    *    Implement an Employee Participation Plan.  
    *    Linpac will perform a Design Review of Compliance with 
         the National Fire Protection Association Codes relevant 
         to the butane system.
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